CJEU clarifies GDPR transparency duties for body-worn cameras

The Court of Justice of the European Union (CJEU) has ruled that personal data captured by body-worn cameras is collected directly from the individual concerned and therefore triggers immediate information obligations under Article 13 of the General Data Protection Regulation (GDPR). The decision was delivered on 18 December 2025 in case C-422/24, following a dispute involving a public transport operator in Stockholm.

The case arose after the Swedish Authority for Privacy Protection fined the transport company for failing to provide adequate information to passengers filmed by ticket inspectors using body cameras. The company challenged the decision, arguing that the data had been collected indirectly and that the disclosure obligations under Article 14 GDPR, which allow for delayed information in certain circumstances, should apply.

The CJEU rejected this argument, holding that data obtained through direct observation of individuals by means of body cameras constitutes direct collection within the meaning of Article 13 GDPR. The Court clarified that direct collection does not require the data subject to knowingly provide information or to take any specific action. Observation-based recording, where the controller is in direct contact with the individual, is sufficient to qualify as direct collection.

As a result, controllers using body-worn cameras must provide required information immediately at the time of data collection. The Court confirmed that this obligation may be fulfilled through a layered approach. Essential information, such as the existence of recording and the identity of the controller, can be communicated via visible warning signs, while more detailed information may be made available in an easily accessible form.

The judgment draws on existing guidance from the European Data Protection Board on video surveillance and reinforces the GDPR’s emphasis on transparency in real-time data processing contexts. It provides clarification for public authorities and private operators using mobile or wearable recording technologies, confirming that transparency obligations apply as soon as individuals are recorded.

While the ruling does not determine the outcome of the underlying national dispute, it is binding on courts and authorities across the EU facing similar questions. The decision is expected to influence how body-worn cameras and other mobile surveillance tools are deployed in practice, particularly in public-facing environments where individuals may otherwise be unaware that their personal data is being processed.